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Responses to Shobdon Regulation 16 Resubmission Consultation

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Responses to Shobdon Regulation 16 Resubmission Consultation Latham, James From: Turner, Andrew Sent: 18 September 2017 15:06 To: Neighbourhood Planning Team Subject: RE: Shobdon Regulation 16 neighbourhood development plan consultation RE: Shobdon Regulation 16 Neighbourhood Development Plan Consultation Dear Neighbourhood Planning Team, I refer to the above and would make the following comments with regard to the above proposed development plan. It is my understanding that you do not require comment on Core Strategy proposals as part of this consultation or comment on sites which are awaiting or have already been granted planning approval. Having reviewed Ordnance survey historical plans, I would advise that three of the four ‘proposed housing sites’(see below) mentioned in policy S4 identified in brown in the ‘Shobdon Village Polices Map’ have been historically used as orchards. By way of general advice I would mention that orchards can be subject to agricultural spraying practices which may, in some circumstances, lead to a legacy of contamination and any development should consider this. (i) Land to north of Moor Meadow; (ii) Land to South of Bar Meadow; (iv) Land west of the Paddocks. Please note, the four proposed housing sites identified on the ‘Shobdon Village Polices Map’ were not marked with their IDs. It would be useful in the future that the sites on the map are given the IDs; (i) to (iv). General comments: Developments such as hospitals, homes and schools may be considered ‘sensitive’ and as such consideration should be given to risk from contamination notwithstanding any comments. Please note that the above does not constitute a detailed investigation or desk study to consider risk from contamination. Should any information about the former uses of the proposed development areas be available I would recommend they be submitted for consideration as they may change the comments provided. It should be recognised that contamination is a material planning consideration and is referred to within the NPPF. I wold recommend applicants and those involved in the parish plan refer to the pertinent parts of the NPPF and be familiar with the requirements and meanings given when considering risk from contamination during development. Finally it is also worth bearingLate in mind that the NPPF response makes clear that the developer and/or landowner is responsible for securing safe development where a site is affected by contamination. These comments are provided on the basis that any other developments would be subject to application through the normal planning process. Kind regards Andrew 1 Latham, James From: Norman Ryan <[email protected]> Sent: 08 September 2017 11:43 To: Neighbourhood Planning Team Cc: Evans Rhys Subject: RE: Shobdon Regulation 16 neighbourhood development plan consultation Attachments: DCWW consultation response - Shobdon NDP - 10 02 17.pdf Dear Sir/Madam, Thank you for consulting Welsh Water on the below resubmission of the Shobdon Regulation 16 Neighbourhood Development Plan. As you may recall, in our previous Regulation 16 consultation response we raised concerns with regard to the accuracy of some of the statements in the Neighbourhood Plan – I have attached this representation for your information. I note from the resubmitted Regulation 16 consultation and the Consultation Statement Addendum that the Parish Council have not amended the inaccuracies or taken on board the recommendations as set out in our original Regulation 16 consultation response. Whilst we appreciate that this is the Parish Council’s prerogative, we would wish to again refute the inaccuracies along with the assertion in the Consultation Statement Addendum “…that the issue is not taken seriously by Welsh Water.” I can assure you that we take the matter of the hydraulic capacity of our sewerage network seriously, and can confirm that at present there are no issues of hydraulic overload on the sewerage network in Shobdon. Further, we do not envisage there being any issues in the growth proposed in the Neighbourhood Development Plan being accommodated. Accordingly, please accept our previous Regulation 16 consultation response along with this email as our representation for the current consultation. If you require any further information then please do not hesitate to contact us. Kind regards, Ryan Norman Forward Plans Officer | Developer Services | Dwr Cymru Welsh Water Linea | Cardiff | CF3 0LT | T: 0800 917 2652| www.dwrcymru.com We will respond to your email as soon as possible but you should allow up to 10 working days to receive a response. For most of the services we offer we set out the timescales that we work to on our Developer Services section of our website. Just follow this link http://www.dwrcymru.com/en/Developer‐Services.aspx and select the service you require where you will find more information and guidance notes which should assist you. If you cannot find the information you are looking for then please call us on 0800 917 2652 as we can normally deal with any questions you have during the call. If we’ve gone the extra mile to provide you with excellent service, let us know. You can nominate an individual or team for a Diolch award through our website. From: Neighbourhood Planning Team [mailto:[email protected]] Sent: 28 July 2017 11:02 Subject: Shobdon Regulation 16 neighbourhood development plan consultation 1 Forward Planning Cynllunio Ymlaen PO Box 3146 Blwch Post 3146 Cardiff Caerdydd CF30 0EH CF30 0EH Tel: +44 (0)800 917 2652 Ffôn: +44 (0)800 917 2652 Fax: +44 (0)2920 740472 Ffacs: +44 (0)2920 740472 E.mail: [email protected] E.bost: [email protected] Shobdon Neighbourhood Plan Enquiries: Rhys Evans/Ryan Norman FAO Herefordshire Neighbourhood Planning Team 0800 917 2652 Sent via email 10th February 2017 Dear Sir/Madam REGULATION 16 PUBLIC CONSULTATION ON SHOBDON NEIGHBOURHOOD PLAN, FEBRUARY 2017 I refer to your email dated the 9th January 2017 regarding the above consultation. Dŵr Cymru Welsh Water (DCWW) appreciates the opportunity to respond and we offer the following representation: Whilst we were consulted at the Regulation 14 stage of the Shobdon Neighbourhood Development Plan in March 2016 and the Parish Council have taken on board some of our comments, we still maintain concern with specific aspects of the document as they are inaccurate. The specific sections that are refuted as being inaccurate are as follows: Policy S4: Meeting Housing Needs within Shobdon Village “No development shall take place until the capacity of the sewer pipe leading to the village sewage treatment works is increased to accommodate additional development”. There are no hydraulic capacity issues on the length of public sewer running from the field to the south of The Grove to the wastewater treatment works (WwTW). Paragraph 5.6 “/However, before any further development can take place measures need to be brought forward to address a constraint in terms of sewerage capacity/” At present, there are no constraints in terms of sewerage capacity in Shobdon. As outlined in our Regulation 14 consultation response, we recommend the addition of the following text to Policy S10, which would protect the sewerage network and WwTW; o Development that may result in the capacity of the wastewater treatment works (WwTW) and/or the public sewerage network becoming overloaded will not be permitted. In either of these instances, development will need to be phased or delayed until capacity becomes available, either through DCWW regulatory investment or, in advance of this through the developer funding the improvements themselves via the provisions of the Water Industry Act (1991) and/or section 106 of the Town and Country Planning Act (1990). 1 Paragraph 5.8 “In particular, works need to be undertaken to enlarge the sewer in the stretch immediately before the Sewage Treatment Works.” As previously stated, there are no hydraulic capacity issues with this sewer. Paragraph 7.2 “The Parish Plan identified drainage problems within the village, in particular, flooding resulting from the sewerage system. It is understood that the issue may still need to be resolved and there is concern that additional development may exacerbate any difficulties. The problem is understood to stem from the installation of temporary pipework put in during the World War 2 and as a consequence, the situation needs at least to be monitored as further developments process. Developer contributions towards appropriate measures should be used to address this issue/” As outlined in our Regulation 14 consultation response, whilst there have been historical incidents of sewer flooding on the public sewerage network, these were not due to hydraulic overload. We will as a matter of course continue to monitor growth within the village, and if there comes a time whereby development would hydraulically overload the sewerage system we would advise the Council accordingly, and would look to either improve the network ourselves or seek developer contributions. However, at the current time there are no issues. Policy S10: Surface and Foul Water Drainage “/Development that may result in the capacity of the Sewage Treatment Works becoming overloaded will not be permitted. Should there be any shortfall in capacity to accommodate development, it will need to be phased or delayed until capacity becomes available. Developments that connect to Shobdon’s main sewer will need to contribute to the upgrading of the sewer pipe between the field to the south of The Grove and the Sewage Treatment Works unless investment by Dwr Cymru Welsh Water has taken place to rectify current problems/” Whilst aspects of this Policy have been amended to take on board recommendations in our Regulation 14 consultation response, it is not wholly accurate. As such, we recommend the suggested wording (under our response to Paragraph 5.6) is included. As aforementioned, there is no hydraulic capacity issue with the sewer leading to the WwTW. Paragraph 7.4 “/Similarly, community concerns have been expressed about leakage from the sewerage system and evidence is available to indicate this is a problem.
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